ITAT Delhi Allows Adjustment of Seized Cash Against Self-Assessment Tax

Kapoor Industries Limited Vs CPC (ITAT Delhi)

Self-assessment tax is an “existing liability” under Section 132B; Seized cash can be adjusted toward it- Restriction under Explanation 2 applies only to advance tax, not to self-assessment tax.

Assessee faced a tax demand of ₹3.74 crore raised by CPC, Bengaluru, during processing of return u/s 143(1) for A.Y. 2024–25. CPC had denied credit for ₹17.66 crore claimed as payment of self-assessment tax, representing cash seized u/s 132 during a search from the director’s locker.

CIT(A) upheld CPC�

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